Circularo Privacy Policy

Posted: December 1st, 2019
Effective: December 1st, 2019
Thanks for using CIRCULARO™ .


In this document, Circularo Europe s.r.o., Identification No.: 068 64 988, with its registered office at Na Folimance 2155/15, Vinohrady, 120 00 Prague 2, registered in the Commercial Register maintained by the Municipal Court in Prague, Section C, File 290373 (“Palaxo or “We”) describes how we collect, use and handle your information when you use our websites, software, our Circularo service and/or other services ("Services").

What kind of information we collect and process

We collect and use the following information to provide, improve and protect our Services:

  • Account. We collect, and associate with your account, information like your name, your title, email address, phone number, payment information, physical address, profile picture,  product purchases and account activity. Some of our services let you access your accounts and your information with other service providers.
  • Services. Our Services are designed to make it simple for you to store any information provided by you in connection with your use of the Services (“Your Content”), collaborate with others, and work across multiple devices. To make that possible, we store, process, and transmit Your Content,as well as information related to Your Content. This related information can be things like your profile information, which makes it easier to collaborate and share Your Content with others.
  • Content Sharing. Our Services may provide you with different options for sharing Your Content. You may choose to give us access to your contacts in order to make it easy for you to do things like share and collaborate on Your Content, send messages, and invite others to use the Services. If you give us access, we'll store those your contacts on our servers consistent with these terms for you to use in connection with the Services.
  • Usage. We collect information related to how you use the Services, including actions you take in your account (like sharing, editing, viewing, signing and moving of files or folders). This helps us provide you with features like the "Recent" page and version history.
  • Devices. We also collect information from and about the devices you use to access the Services. This includes things like IP addresses, the type of browser and device you use, the web page you visited before coming to our sites, and identifiers associated with your devices. Your devices (depending on their settings) may also transmit location information to the Services and Palaxo may collect this information depending on the permissions you provide in your device. 
  • Cookies and other technologies. We use technologies like cookies and pixel tags to provide, improve, protect and promote our Services. Cookies help us with things like remembering your username for your next visit, understanding how you are interacting with our Services, and improving them based on that information. You can set your browser to not accept cookies, but this may limit your ability to use the Services.

With whom we can share your information

We may share information as discussed below, but we won't sell it to advertisers or other third parties.

  • Others working for Us. Palaxo uses certain trusted third parties (for example, providers of customer support and IT services) to help us provide, improve, protect, and promote our Services. These third parties will be provided only with anonymous user data and never with your personal data. Any information shared with third parties in this way complies with this Privacy Policy, and we'll do our best to be responsible for the handling of your information.
  • Other users. Our Services display information like your name, profile picture, and email address to other users in places like your user profile and sharing notifications. When you register your Circularo account with an email address on a domain owned by your employer or organization, we may help collaborators find you and your team by making some of your basic information—like your name, team name, profile picture, and email address—visible to other users on the same domain. This helps us show you teams you can join, and helps other users share files and folders with you. Certain features let you make additional information available to others.
  • Other applications. You can also give third parties access to your information and account - for example, via Circularo APIs. Just remember that their use of your information will be governed by their privacy policies and terms.
  • Circularo Team Admins. If you are a member of a Circularo team your administrator may have the ability to access and control your Circularo team account. Please refer to your organization's internal policies if you have questions about this. If you are not a Circularo team member, but interact with a Circularo team user (for example, by joining a shared folder or accessing content shared by that user), members of that organization may be able to view the name, email address, profile picture, and IP address  that was associated with your account at the time of that interaction.Your administrator may customize your Circularo team settings so that others can view additional information. Please refer to your organization’s internal policies.
  • Law & Order. We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to (a) comply with the law; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of our Services or our users; or (d) protect Circularo's property rights. Stewardship of your data is critical to us and a responsibility that we embrace.
  • Security. We take security seriously and work hard to ensure our products reflect industry standards. Please contact us if you would like further information about how we do this.

For how long will your information be retained

We'll retain information you store on our Services for as long as you use the Services or for as long as we need it to provide you the Services.

If you delete your account, we'll also delete this information promptly. However, we may not delete your account information promptly or at all, (1) if there is latency in deleting information from our servers and back-up storage or if (2) necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.

To provide you with the Services, we may store, process and transmit information in the United States and locations around the world - including those outside your country. Information may also be stored locally on the devices you use to access the Services.


Palaxo is an ‘Administrator’ under Article 13 of the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data (“Regulation” or “GDPR”), which sets out important principles of personal data processing (“Principles”). The purpose of processing under these Principles is primarily the provision of the Services, including the operation of the website, as well as marketing and other activities related to our business. These may be related but detailed information about each is set out below.

Providing Circularo Services

If you use Services relating to Circularo (“Circularo Services”), we process the personal data that we need to provide you with the Circularo Services to the extent and quality you are interested in.

Scope of Processing. Your personal data is processed only to the extent necessary and primarily includes the following categories of data:

  • Identification data (e.g. first name, surname, IP address)
  • Contact data (e.g. e-mail address, phone number)
  • Business data (e.g. employer, job)
  • Technical data (e.g. your device ID, IP address, location data)
  • Operational data on the application/solution provided (e.g. error message)
  • Or other data not classifiable in these categories that the Administrator obtains in connection with the provision of the Circularo services

We do not have access to Your Content unless you give us permission to access Your Content. We are a ‘Processor’, not an ‘Administrator’, with respect to Your Content.

Legal Basis of Processing. The legal basis for processing is:

  • Performance of contractual obligations - if you use the Circularo Service, prior to using the Circularo Service, you will enter into certain agreements with us. In order to provide you with the agreed services, we need some of your personal data. The legal basis for processing is the performance of the relevant agreement;
  • Performance of legal obligations - we must keep some personal data of yours in accordance with the laws and regulations in force in the Czech Republic, in particular with accounting and tax regulations. The legal basis for processing is compliance with legal regulations;
  • Our legitimate interest - our legitimate interests, in relation to technical and operational data about how you use the application, include the continual improvement of the Circularo Services. The legal basis for processing a legitimate interest in improving services. We also need this data for the smooth provision of the Circularo Services and upon termination of the service provision for our legal protection. The legal basis for processing is the performance of relevant agreement and legal protection.

Period of Processing. We process your personal data for as long as is needed. In particular:

  • During the Service period - we continuously anonymize technical data and the data on service operation/functioning
  • At expiry or termination of the Service period –  we anonymize usable data and delete personal data that we no longer need. We keep other personal data for a period of time laid down by law, provided we have such legal obligations, or for our legal protection, after the service provision has been terminated.

Operation of the Website

If you visit any our websites, including or (“Websites”) es other than to use Circularo Services (or before the use of these services), we process some of your personal data to ensure the smooth operation of the Websites, user comfort, and regular improvement. You can also contact us via our website to provide us with some of your personal data.

Scope of Processing. Your personal data is processed only to the extent necessary, depending on the extent to which you use our website. This mainly includes the following categories:

  • Identification data (e.g. first name, surname, IP address)
  • Contact data (e.g. e-mail address, phone number)
  • Technical data (e.g. your device ID, IP address)
  • Operational data on the website (e.g. time spent on the website)
  • Cookies and social plug-ins, which, however, are subject to our “cookies policy”.

Legal Basis of Processing. The legal basis is our legitimate interest in monitoring the use and operation of our Websites, visitors, and user comfort. We also have a legitimate interest, if you contact us via forms on our Websites, in receiving feedback, tips, or suggestions from you or generating business .

Period of Processing. We process your personal data for as long as needed. In particular:

  • we continuously anonymise the technical data and the data on the service operation/functioning;
  • we keep any communication sent to us through the Websites for a period of 5 years.;
  • we keep other personal data for a period of time laid down by law, provided we have such a legal obligation, or for our legal protection, for 10 years after you use the Websites.

Related Business Activity. If you visit our Websites, or use Circularo Services, we also use some of your personal data for the purpose of our business activities as well as various forms of marketing; in particular, maintaining a database of customer contact data and business partners,.

Scope of Processing. The personal data is processed only to the extent necessary. This mainly includes the following categories:

  • Identification data (e.g. first name, surname)
  • Contact data (e.g. e-mail address, phone number)
  • Business data (employer, job)

Legal Basis of Processing. The legal basis is our legitimate interest in having knowing of our business partners in order to carry out our business activities, and our legitimate interest in marketingto increase awareness of the products and services that we offer. All this applies to a reasonable extent and with respect for the privacy of our business partners. The set of contacts is part of our know-how and enables us to carry out business activities efficiently in our field, and maintaining our know-how is also our legitimate interest.

Period of Processing. We process this personal data only until you object to it. If you submit your objections (or any statement that you are not interested in marketing or keeping of your contact data in our contacts list), we will erase this personal data, unless we have another legal basis to process it, and we will stop using it for that purpose. We will also inform you about the option of refusing marketing in every marketing communication.

Sharing of Personal Data

Third Parties. We do not process your personal data independently, but we do so in cooperation with trustworthy partners and suppliers. The categories of recipients include providers of technical support, cloud and web hosting solutions, suppliers in the field of marketing, accounting, legal, marketing, or similar consultants, as well as other persons with whom we cooperate.

Location. We process your personal data primarily in the European Union, but some of our processors and partners may be located outside the Czech Republic and the European Union. In this case, we make sure that they guarantee to the greatest extent possible that the personal data is protected and we act in accordance with the European Union law when dealing with them, in particular by using standard contractual clauses approved by the European Commission. In addition to the European Union, our partners may also be located in the United States of America, the United Arab Emirates, Australia, India, or other countries. In this case, however, full GDPR compliance at a high level and a high level of personal data protection is ensured when dealing with them. 

Your Rights pursuant to the GDPR

Rights. In accordance with the GDPR, you have the right to correct or complete the incomplete personal data, request processing restriction, complain against the personal data processing, request personal data transfer, access your personal data, be informed of personal data leakage, request personal data deletion, and other rights as laid down by the GDPR.

Objections. You have the right to object to the processing based on the legitimate interest of the Administrator to the e-mail address above. If the objections relate to direct marketing, we will always accept these objections.

Withdrawing Consent. If you have ever given us consent, you can withdraw it at any time. This does not affect the lawfulness of processing prior to the consent withdrawal.

More Information. You can find more information on the GDPR rights on the website of the Office for Personal Data Protection. ( We have not appointed a personal data protection officer, but you can always contact us as the Administrator by e-mail: or by post to the address of our registered seat (Na Folimance 2155/15, Vinohrady, 120 00 Prague 2). We may require you to prove your identity to prevent unauthorised persons from accessing your personal data.

Complaints. You have the right to lodge a complaint to the supervisory authority regarding the personal data processing or the failure of the Administrator to fulfil the GDPR obligations. The supervisory authority is the Office for Personal Data Protection, with its registered office at Pplk. Sochora 27, 170 00 Prague 7,

General provisions

Transfer. If we are involved in a reorganization, merger, acquisition or sale of our assets, your information may be transferred as part of that deal. We will notify you of any such deal and outline your choices in that event.

Changes. We may revise this Privacy Policy from time to time, and will post the most current version on our website. If a revision meaningfully reduces your rights, we will notify you.

Notices. Any communication sent by us under this Policy by email to the email address provided by you in connection with a Service.

Have questions or concerns about our Services and privacy? Contact us at